How to determine whether a business partner/counterparty is connected with the Russian Federation?

During martial law in Ukraine, it is especially important to check business partners for any links to the Russian Federation. This helps avoid legal, financial, and reputational risks. Here are the main steps for such a check:

• Analysis of Company Registration Data: Check if the company or its founders are registered in Russia. This information can be obtained from official registers or specialized services such as YouControl.
• Verification of Ultimate Beneficial Owners (UBOs): Identify the individuals who actually control the company. If any of them are citizens or residents of the Russian Federation, this may indicate a connection to Russia.
• Analysis of Company Activities: Determine whether the company conducts transactions with Russian businesses or operates within the territory of the Russian Federation. This can be done by checking public reports, news, and other open sources.
• Check Sanctions Lists: Ensure that the company or its managers are not included in international or Ukrainian sanctions lists. This can be done on the official websites of relevant authorities.
• Request for Confirmation of No Links to the Russian Federation: Send an official request to the counterparty asking for written confirmation that there are no links to the Russian Federation.
• Include a Relevant Clause in the Contract: When entering into an agreement with a counterparty, it is advisable to include a clause obligating the party to confirm the absence of any links to Russia and to inform about any changes in this status.